WASHINGTON — FormerFeds LLC today announced that it had chosen the name “PerfectShield™” for its flagship revolutionary Compliance system that designed and deployed by former American fraud enforcers (a/k/a “FormerFeds”). FormerFeds LLC has been developing PerfectShield™ as the newest weapon in the legal community’s arsenal to provide a ‘redundant complex risk prevention array’ for law firm clients that is affordable and provides automated and organized support for a company’s compliance operations overseen and administered by law firms.

Said Susan Herrmann, President of FormerFeds LLC, “we thought that PerfectShield typified in one term what we hope that our software compliance assessment solution will be able to provide to law firms in providing top notch legal service to their clients.”

COMPLIANCE

We focus and direct our primary compliance efforts on corporate clients that are active in Africa, Asia and the Middle East because, let’s face it, compliance related issues will continue to be an aspect of doing business in a number of countries in these regions of the world. We devote significant resources to the development, maintenance, communication and enforcement of our Business Code of Conduct for these corporate clients and we expend significant resources developing anti-bribery compliance policies, our internal control processes and procedures, and other compliance related policies.

Separately and also sometimes as part of a client’s compliance program, we will conduct timely internal investigations of any potential violations and take appropriate action depending upon the outcome of the investigation. Sometimes this appropriate action is to leave the matter addressed “in-house; other times the appropriate action is to refer the matter to an outside law firm.

Compliance-related issues have limited the ability of many companies to do business and/or have raised the cost of operating in these countries. We seek to use our network of FormerFeds to reduce your risk and expand your business horizons so that you can provide products and services to these countries that need them. Sometimes, modern business realities require companies to utilize ventures with third parties, sell products to distributors or otherwise modify a “textbook” business approach to remain competitive. FormerFedsCompliance recognizes these realities, appreciates the additional risk these competitive realties bring and can help you improve your ability to conduct your business in accordance with applicable laws and regulations and your FormerFeds Business Code of Conduct.

We will help you design and implement a Global Ethics and Compliance Program (“Compliance Program”) based on (1) Core Values of Integrity, Performance, Teamwork and Learning; (2) the standards contained in your FormerFeds Business Code of Conduct; and (3) the laws of the countries where you operate. Your compliance program, if effective, should help your organization become ‘completely compliant’ with “Tone-at-the-Top” through all branches of operation throughout the Company. You employees should be consistently reminded that they play a crucial role in ensuring that the Company always conducts its business ethically, legally and safely.

Highlights of the FormerFedsCompliance Program include the following:

We can share comprehensive internal guidance regarding such areas as facilitating payments; travel, entertainment, gifts and charitable donations connected to non-U.S. government officials; payments to non-U.S. commercial sales representatives; and the use of non-U.S. police or military organizations for security purposes. In addition, we have country-specific guidance for customs standards, export and re-export controls, economic sanctions and anti-boycott laws.

We have a comprehensive employee compliance training program covering substantially all employees. We are flexible and can meet most reasonable budgets (if you are an NGO ask about our NGO rates).

We have a due diligence procedure for commercial sales, processing and professional agents, an enhanced process for classifying distributors and are creating a formal policy to guide business personnel in determining when subcontractors should be subjected to compliance due diligence.

When necessary we can form a special compliance committee comprised of FormerFeds from enforcement agencies that are most likely to reach out and touch your operations.

We can help you reduce your use of commercial sales representatives, processing agents and customs agents while we provide a plan for mitigating current risks.

We can use technology to monitor and report on compliance matters, including 3rd party provided general compliance tools.

We can implement a program that encourages reporting of any ethics or compliance matter without fear of retaliation including a worldwide complaint hotline.

We can help your corporate audit function uncover areas of vulnerability and even victimization (procurement) and we can incorporate additional anti-corruption procedures in audits of certain countries. We are also continuing to refine and enhance our procedures for FCPA risk assessments and legal audit procedures.

We continue to work to ensure that we have adequate legal compliance coverage around the world, including the coordination of compliance advice and training across all regions and countries where we do business.

We are continuing to incorporate changes that help clients implement consistent standards for pre-hire screening of employees, the screening of existing employees prior to promoting them to positions where they may be exposed to corruption-related risks, and creating a uniform policy for new hire training.

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Disclaimer

Important: FormerFeds, LLC is not a law firm. We do not provide legal advice. Our PerfectShield™ compliance solution should always be administered with the advice and under the guidance of legal counsel. Read more →